MCCLATCHEY v. ASSOCIATED PRESS
Filing
11
Joint MOTION to Extend Time forDiscovery by VALENCIA M. MCCLATCHEY. (Attachments: # 1 Exhibit Notice of Motion# 2 Proposed Order)(Hall, John)
MCCLATCHEY v. ASSOCIATED PRESS
Doc. 11
Case 3:05-cv-00145-TFM
Document 11
Filed 12/02/2005
Page 1 of 3
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA
VALENCIA M. MCCLATCHEY
Plaintiff
Civil Action No. OS- 145J
THE ASSOCIATED PRESS
JURY TRIAL DEMANDED
Defendant.
JOINT MOTION FOR AN EXTENSION OF TIME
Plaintiff Valencia McClatchey, and Defendant The Associated Press, by and through
their attorneys, hereby submit this Joint Motion for an Extension of Time. In support of the
agreed motion ,
Plaintiff and Defendant state as follows.
On July 2S , 2005, this Court entered a Case Management Order and set the
following dates:
Close of Fact Discovery
Expert Reports
Responses to Expert Reports
December 2 , 2005
December 15, 2005
January 13, 2006
January 31
Expert Depositions
2006
Deadlines for Motions for Summary Judgment February 3, 2006
Plaintiffs pretral narrative statement
Defendant's pretrial narrative statement
February 21 ,
2006
March 14 , 2006
Joint statement re: magistrate judge
March 28, 2005
Since the Court's Case Management Order,
the parties
have
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Case 3:05-cv-00145-TFM
Document 11
Filed 12/02/2005
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exchanged documents and written discovery. The parties have been attempting to set
deposition dates. However, due to witnesses' schedules , the parties wil be unable to
complete faCt discovery by December 2 , 2005.
Accordingly, the partes jointly seek a 60-day extension of time and an order
setting the following revised schedule:
Close of Fact Discovery
Expert Reports
February 1, 2006
February 15 ,
2006
Responses to Expert Reports
March 13
2006
Expert Depositions
March 31. 2006
Deadlines for Motions for Summary Judgment April 3, 2006
Plaintiffs pretrial narrative statement
Defendant's pretrial narrative statement
April 21, 2006
May 15, 2006
May 31, 2005
Joint statement re: magistrate judge
WHEREFORE , Plaintiffs and Defendant respectfully request that the Court approve
the 60-day extension of time and enter the revised schedule above.
Respectfully submitted
VALENCIA MCCLATCHEY
Douglas M.
ert Penchi a
evine Sullvan Koch & Schulz, LLP 230 Park Avenu . Suite 1160 New York, NY 10169 Phone: 212-850-61 00
Kara L Szpondowski
Niro, Scavone, Haller & Niro
181 W. Madison, Suite 4600 Chicago , Ilinois 60602
Phone: 312-236-0733
Fax: 212-850-6299
Fax: 312-23 -3137
ohn E. Hall
Eckert Seamans Cherin & Mellott
600 Grant Street
ICA/
ittsburgh PA 15219
, 44th Floor
2(
412. 566. 1915
Case 3:05-cv-00145-TFM
Document 11
Filed 12/02/2005
Page 3 of 3
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true copy of the foregoing MOTION FOR AN EXTENSION OF TIME
JOINT was served upon the below listed parties on
this 1
day of December, 2005:
Gayle C. Sproul Levine Sullivan Koch & Schultz, LLP 2112 Walnut St. , 3 Floor
By Mail:
Philadelphia, PA 19013
Phone: (215) 988-9778
By Facsimile and Mail:
Robert Penchina
Levine Sullivan Koch & Schultz, LLP 230 Park Avenue
Suite 1160
New York, NY 10169 Phone: (212) 850-6100
Fax: (212) 850-6299
Jo
Hall 1;L1e I t9
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